The IHBC has submitted its response to Historic England Advice Note on Listed Building Consent – which offers both general advice for owners of listed buildings and on how to judge whether proposals need consent etc.
The IHBC writes:
… should take into account… large number of Local Authorities which have no specialist conservation advice…
General comments… This advice note should take into account that expert input is needed regarding LBC and any follow ups to approvals. A very real issue in this context is the lack of Local Planning Authority specialist staff. Especially in those large number of Local Authorities which have no specialist conservation advice available from a Conservation Officer or equivalent, to assess an application with the appropriate expertise….
… still need to be expert input regarding assessment of buildings etc…
Legal and policy background… There are currently huge inconsistencies between LPA practices concerning the assessment, processing and decision-making on LBC. This advice highlights the importance of having an understanding from the start of where special interest in a listed building lies. There will always be a grey area over some issues and there will still need to be expert input regarding assessment of buildings etc for LBC and follow ups to any approvals if necessary. To say the advice is given ‘on works which may or may not need listed building consent, depending on how the works are proposed to be carried out’ is too vague as the purpose is surely to remove the ambiguity that prompted the advice note in the first place. The relationship of this Advice Note to HEAN2 needs clarification….
… Guidance will not enable people to deal with complex problems if they do not have a proper understanding of heritage significance (and what is not significant) and of conservation principles. This can lead to the loss of important historical material but, at the other end of the scale applications should not be required when not needed. This attempt to make sense of a complex subject is to be welcomed, but most importantly the point must be made that there is a need to employ people who properly understand significance and conservation. The guidance should be clear it is not a do it yourself manual for LBC….
Download the full response